Depreciation Recapture. Solely for tax purposes, a Member's share of the Company's depreciation recapture recognized for tax purposes upon the disposition of Company property shall be computed in the manner provided for in sections 1.704-3(a)(11), 1.1245-1(e) and 1.1250-1(f) of the Income Tax Regulations. The provisions of this Section 9.1(d) are intended to affect only the character of the items of gain allocated by the Company to the Members. This Section 9.1(d) shall not affect the aggregate amount of gain (including gain characterized under this Section 9.1(d) as depreciation recapture) otherwise allocable to a Member pursuant to this Section 9.1.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Chevron Phillips Chemical Co Lp), Limited Liability Company Agreement (Chevron Phillips Chemical Co LLC), Limited Liability Company Agreement (Phillips Petroleum Co)
Depreciation Recapture. Solely for tax purposes, a Member's ’s share of the Company's ’s depreciation recapture recognized for tax purposes upon the disposition of Company property shall be computed in the manner provided for in sections 1.704-3(a)(11), 1.1245-1(e) and 1.1250-1(f) of the Income Tax Regulations. The provisions of this Section 9.1(d) are intended to affect only the character of the items of gain allocated by the Company to the Members. This Section 9.1(d) shall not affect the aggregate amount of gain (including gain characterized under this Section 9.1(d) as depreciation recapture) otherwise allocable to a Member pursuant to this Section 9.1.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Phillips 66), Consent Agreement (Phillips 66), Limited Liability Company Agreement (Phillips 66)
Depreciation Recapture. Solely for tax purposes, a Member's share of the Company's depreciation recapture recognized for tax purposes upon the disposition of Company property shall be computed in the manner provided for in sections 1.704-3(a)(11), 1.1245-1(e) and 1.1250-1(f) of the Income Tax Regulations. The provisions of this Section 9.1(d8.1(f) are intended to affect only the character of the items of gain allocated by the Company to the Members. This Section 9.1(d8.1(f) shall not affect the aggregate amount of gain (including gain characterized under this Section 9.1(d8.1(f) as depreciation recapture) otherwise allocable to a Member pursuant to this Section 9.18.1.
Appears in 1 contract
Depreciation Recapture. Solely for tax purposes, a Member's share of the Company's depreciation recapture recognized for tax purposes upon the disposition of Company property shall be computed in the manner provided for in sections 1.704-3(a)(11), 1.1245-1(e) and 1.1250-1(f) 1(0 of the Income Tax Regulations. The provisions of this Section 9.1(d) are intended to affect only the character of the items of gain allocated by the Company to the Members. This Section 9.1(d) shall not affect the aggregate amount of gain (including gain characterized under this Section 9.1(d) as depreciation recapture) otherwise allocable to a Member pursuant to this Section 9.1.
Appears in 1 contract
Samples: Contribution Agreement (Chevron Phillips Chemical Co LLC)